You made the Filing Deadline! Now what?
Congratulations! You made the 2023 E-Rate filing deadline. It might feel like the hard part is over, but we’d like to caution you not to think your E-Rate paperwork is anything close to being “done.”
The tail end of a filing window is the perfect time to think about compliance for the upcoming funding year. The paperwork and documents you just filed are critical to securing your funding, as you already knew; however, they’re also crucial to keeping your funding.
Documents used in the E-Rate process must be retained for ten years after the last date of service. Without a follow-up process and knowledge of what to hold onto, the ten-year window of compliance can quickly become a nightmare.
Now is the time to develop a follow-up process that will ensure all documents are filed correctly and that vendors are adhering to the required standards.
Here’s how you can begin:
What is Document Retention?
Document retention is the process of keeping records and documents for a certain period of time. Any organization that has received funding from the government, including schools and libraries, must hold onto a litany of documents for a period of time.
The Federal Communications Commission (FCC) requires that program participants retain all documents necessary to demonstrate compliance with the statute and Commission rules regarding the application for, receipt, and delivery of services receiving schools and libraries discounts. Schools, libraries, and service providers are subject to both random audits and to other audits (or investigations) to examine an entity’s compliance with the statute and the Commission’s rules initiated at the discretion of the Commission, USAC, or another authorized governmental oversight body.
The FCC adopted the E-Rate Modernization Order on July 11, 2014, extending the document retention period to 10 years after the latter of the last day of the applicable funding year or the service delivery deadline for the funding request.
Why is Document Retention Important?
Maintaining records is critical for the E-Rate program because it helps to ensure the accuracy of the program, protects applicants from fraud, and allows for easy access to records and documents when needed.
What Documents Should be Retained?
The E-Rate program has strict requirements that applicants should retain all documents related to the program, including:
- Bid requests and vendor proposals
- Vendor evaluations
- Signed contracts or amendments
- Board meeting minutes
- Communications with vendors, such as emails
- Invoices, proof of payment, or reimbursements
- Consultant or consortium Letters of Agency (LOA)
How Long Should Documents be Retained?
Documents should be retained for a minimum of ten years after the latter of the last day of the applicable funding year or the service delivery deadline for the funding request. This retention includes all documents that support your funding requests and other related activities, including:
- Financial audits, reviews and/or attestations
- Grant awards, agreements and amendments
- Contractor performance reports (e.g., monthly invoices)
Where Should Documents be Stored?
Documents should be stored in a secure location and should be accessible to authorized personnel only. The E-Rate program requires that all documents used to support an application be retained for ten years or more. There are many great ways to retain your records
- Google Drive
- Local server
Do You Have the Vendor Proposals and Vendor Communications?
Now that the ECF and E-Rate filing deadlines have passed, it's time to start gathering all documents related to your vendor proposals. Include emails, contracts, and copies of any other communications. If you're unsure whether or not your organization has these documents in its possession, speak with IT staff members who may have been involved in the process at some point during this or previous years’ procurement process.
Competitive Bidding Process Documents
The first step to ensuring that you're prepared for the next round of E-Rate funding is to make sure you have all the documents related to the competitive bidding process, and evaluation process, including board approvals, bid requests and any other documents related to the process.
If you don't have these documents in hand, it will be difficult to move forward with preparing your application.
Signed Contracts or Legally Binding Agreements
- Make sure all contracts have been signed by both parties and that the signed contracts have been filed with the proper authorities.
- Services to be delivered under non-contracted, tariffed, or month-to-month arrangements do not require a contract
- Must demonstrate that a contract or other legally binding agreement in place at the time FCC Form 471 is certified.
- Must also comply with state and/or local contract law.
Now that the filing deadline has passed, it's time to gather all the data you need, including school enrollment, the number of students who qualify for free or reduced lunch, and any other relevant information.
You can find this information in your district's E-Rate application or on their website if they haven't yet submitted an application.
If you are audited, the government will want to know how the vendors were selected. Your records should include bid requests, proposals received, evaluation criteria, and any other documents related to the process. These documents can help you prove that a thorough process was utilized to choose the current service provider.
These documents are requested for most USAC audits or heightened reviews.
Do You Have the Vendor Proposals and Vendor Communications?
Once you've confirmed that your E-Rate filing is complete and approved, it's time to start thinking about next year's procurement process. The first step in this process is getting organized so that you can make sure all documents related to the vendor proposals are available when needed.
The following documents should be part of your E-Rate filing package:
- All emails between school staff members and vendors regarding E-Rate purchases or other matters related to the program (including attachments)
- Contracts signed by both parties as well as any amendments or addendums made during negotiations for those contracts
- Any other communications between school staff members and vendors regarding items purchased under an existing contract
Vendor Delivery of Service
Supporting your community or students with a stable and adequate technology infrastructure is the foundation of 21st Century learning and preparation for the digital economy. With that, vendor delivery of service is one of the most important factors in determining whether you will receive funding. This means that you should view vendor completion of installation of equipment, and circuits, and review invoices throughout the process. If you have any questions or concerns, contact your E-Rate team immediately. The last thing you want to do is wait until there is a heightened review or audit before discovering any issues with your vendors.
If this feels like a lot– that’s because it is! Compliance can feel overwhelming and at times, impossible to navigate. It can also be tempting to give yourself a paperwork break after meeting this year’s deadline. Be rigorous! Vetting your process now will save you time, headaches, and money in the future. To make sure you’re headed in the right direction, book a free strategy audit with our experts today!